Conflicts of Interest Disclosure Procedures

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Abstract

At Endaoment, upholding the highest standards of integrity and ethical conduct is paramount. This document outlines the procedures for disclosing and managing conflicts of interest within our organization.

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Disclosure Procedures

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1. Identification of Potential Conflict

• Initial Identification: Any Endaoment team member who suspects they may have a conflict of interest should initially assess the situation against the organization’s conflict of interest policy.

• Consultation: If uncertain, the team member should consult with their supervisor for guidance.

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2. Formal Disclosure

• Disclosure Form: The individual must complete a Conflict of Interest Disclosure Form. This form will be available on Endaoment’s internal portal and in hard copy from the HR department.

• Detailed Description: The form should include a comprehensive description of the potential conflict, including the nature of the personal interest and its overlap with Endaoment’s activities.

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3. Submission of Disclosure

• Direct Submission: The completed form should be submitted directly to the designated ethics mailbox.

• Confidential Handling: All disclosures will be treated with the utmost confidentiality, and in line with our anti-retaliation practices.

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Review and Decision-Making Process

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1. Initial Review

• Assessment: The designated officer will conduct an initial review of the disclosure to determine the extent of the conflict.

• Consultation with Senior Management: If necessary, the officer may consult with senior management, the board, or legal advisors for additional perspective.

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2. Decision Making

• Ethics Committee Review: Complex or significant conflicts will be escalated to the Ethics Committee for a detailed review.

• Decision and Recommendations: The Ethics Committee will decide on the appropriate action, which may range from no action needed to adjustments in duties or decision-making roles.

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3. Communication of Decision

• Feedback to the Individual: The individual who disclosed the conflict will be informed of the decision and any necessary actions they need to take.

• Ongoing Monitoring: The situation will be monitored to ensure that the conflict is managed effectively.

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Record Keeping and Transparency

• Documentation: All disclosures and actions taken will be documented and securely stored.

• Annual Review: The officer will conduct an annual review of all conflict of interest disclosures to identify any patterns or systemic issues.

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Training and Support

• Regular Training: Endaoment will provide periodic training to all staff on conflict of interest identification and disclosure procedures.

• Support and Guidance: Ongoing support and guidance will be available to help staff navigate and adhere to these procedures.

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Reporting Violations

• Whistle-blower Protection: Endaoment provides a secure and confidential channel for reporting any violations or concerns regarding conflicts of interest, with protection against retaliation.

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Continuous Improvement

• Policy Review and Updates: The conflict of interest policy and disclosure procedures will be reviewed regularly and updated as necessary to reflect changes in the organization and regulatory environment.

Endaoment is committed to ethical excellence and expects all team members to adhere to these procedures to maintain trust and integrity in all our operations.